“Plaintiff is not entitled to recover damages for future economic losses that Defendant proves Plaintiff will be able to
avoid by returning to gainful employment as soon as it is reasonable for him to do so. If you decide that Plaintiff will be able to return to work, then you must not award him any damages for the amount he will be able to earn from future
gainful employment. To calculate the amount of damages you must: 1. Determine the amount Plaintiff would have earned from the job he held at the time he was injured; and 2. Subtract the amount Plaintiff is reasonably able to earn
from alternate employment. The resulting amount is Plaintiff’s damages for future lost earnings.”
[CACI Jury Instructions [citations omitted]]
